Jack Holzknecht just posted the Q&A from the Insider Lending webinar. I need a little help with number 10.

Q: What about Bank Holding Company Directors and Executive Management who are not Bank Directors or Executive Officers?

A: Directors and executive officers of the holding company are considered "executive officers" of the bank for Reg O purposes.

What if they are directors of the Bank and the Bank Holding Company. Do I categorize them as Directors or Executive Officers? Then if I categorize them as Executive Officers are they subject to the stricter lending limits imposed on bank executive officers?

Not to speak for Jack, but I think he probably meant to say that directors of the holding company are considered directors of the bank and executive officers of the holding company are considered executive officers of the bank for Reg O purposes. At least that's my understanding of the rules.

Jim - Thanks for stepping in for me. I just got back in from a seminar road trip. Your understanding of the rules is perfect. Your clarification is crystal clear.

Thanks for the clarification! Reg O is always a tightrope!